State v. Armstrong, 2016 Ohio 7841

Background

Appellant Derick Armstrong traveled with Mitchell White and White’s 17‑year‑old girlfriend A.M.; they stayed at the Hiram Inn where police later found drugs, needles, a handgun, scales, small bindle bags, ~16.16 g powdered meth in a box, and a small meth amount (~0.21 g) in a West Virginia backpack belonging to Armstrong.
A.M. tested positive for amphetamine, meth, methadone, opiates and told medical staff she had been injecting meth that day and previously; officers found a small amount of meth in her purse.
Armstrong admitted ownership of the WV backpack and some suboxone pills, denied providing meth to A.M., denied injecting with A.M. or White, and denied knowledge of the large quantity of meth in the box.
Indictment included multiple counts; jury convicted Armstrong of corrupting another with drugs (R.C. 2925.02(A)(4)(c)) alleging he induced a juvenile to commit a felony drug offense involving meth, and of lesser aggravated possession (he does not challenge the latter).
The court sentenced Armstrong to five years on the corrupting‑another count (concurrent with 11 months). On appeal the issue was whether the corrupting‑another conviction was supported by sufficient evidence and not against the manifest weight of the evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prosecution proved Armstrong knowingly induced or caused a juvenile to use meth (element of R.C. 2925.02(A)(4)(c))	State relied on evidence that A.M. injected meth that day, meth was present in the hotel room, and Armstrong had some meth/suboxone in his possession — jury could infer he provided it	Armstrong argued the evidence did not tie the meth A.M. used to him; other plausible sources existed (large box, White, A.M. herself, third parties); he consistently denied providing meth	Reversed: conviction not supported — state failed to prove beyond reasonable doubt Armstrong was source of the meth A.M. used; inference stacking impermissible
Whether prosecution proved Armstrong knew A.M. was a juvenile or was reckless as to age	State pointed to Armstrong’s statement noting she looked young and his responsibility for her	Armstrong said White told him she was not a minor and he denied knowledge she was underage	Court did not reach independent reversal on age element; primary reversal rests on insufficiency of evidence as to inducement/source of meth
Whether evidence supporting corrupting‑another could rest on drugs other than meth (e.g., suboxone)	State introduced evidence Armstrong possessed suboxone and A.M. admitted taking suboxone that day	Armstrong noted indictment specifically alleged meth; trial evidence of suboxone was not charged and could not substitute for proof of meth in the indicted count	Court held indictment charged corruption involving meth specifically; conviction cannot be sustained based on uncharged drug (suboxone) — verdict would be a nullity if based on that drug
Whether conviction was against manifest weight when based on circumstantial evidence	State argued circumstantial evidence may be as probative as direct evidence and reasonable inferences supported guilt	Armstrong argued inference‑stacking was required and the verdict was based on speculation and conjecture	Court found conviction rested on impermissible stacking of inferences and speculation; manifest weight/sufficiency not met for meth‑based corruption

Key Cases Cited

State v. Jenks, 61 Ohio St.3d 259 (establishing that circumstantial and direct evidence have the same probative value)
State v. Nicely, 39 Ohio St.3d 147 (definition and treatment of circumstantial evidence)
State v. Nevius, 147 Ohio St. 263 (definition of an inference in criminal proofs)
State v. Noling, 98 Ohio St.3d 44 (due process right to notice of specific charge and necessity of specific indictment allegations)
Cole v. Arkansas, 333 U.S. 196 (constitutional requirement of notice of the specific charge)